What is "money returning to the US"? If Apple US foreign activities earned income, they need to tax that income. If Apple Ireland earned income, they need to ta

What is "money returning to the US"? If Apple US foreign activities earned income, they need to tax that income. If Apple Ireland earned income, they need to tax that income in Ireland and there is no "repatriation" tax. Apple says Apple Ireland has no income since all of its profits go towards paying licensing fees to Apple US. So it's income for Apple US, but they haven't paid the tax on it? Right now that money seems to be in limbo with no one having paid any tax on it. If Apple wants to recognize that as US income, surely they should be paying the tax on it. But let's not create some tax holiday so large companies can pay zero tax on foreign activities.